A common cross-border reorganization can doom eligibility for the valuable gain exclusion without thoughtful planning.
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Tax Insider Articles
The proposed PTEP rules: Tax basis considerations under Sec. 961
Proposed regulations for previously taxed earning and profits of foreign corporations address a range of considerations for shareholder basis adjustments.
Using transfer pricing to blunt the effects of tariffs
Understanding the interrelationship of transfer pricing and tariffs is key to mitigating the effect of those levies on earnings.
Disregarded-payment-loss rules: How multinationals should prepare
New final regulations pose significant implications for possible income inclusions by U.S. corporations with foreign disregarded entities.
Elections under the new Sec. 987 final regs.
Businesses with foreign branches receive new guidance on adjusting for currency exchange gain or loss.
Placing in service the benefits of the Inflation Reduction Act
Determining when energy property is eligible for a tax credit or deduction hinges on when it is first placed in service, which can be controversial.
Incentives for solar power generation systems
Tax benefits are available to taxpayers who generate their own electricity from solar power generation systems whether the system is for personal or business use.
Limiting the unlimited charitable deduction for trusts
Although Sec. 642(c) provides for an โunlimitedโ charitable income tax deduction attractive to philanthropic grantors, Sec. 681 may limit a trustโs actual deduction.
Early terminations of QTIP trusts: The cautionary case of McDougall
Qualified terminable interest property trusts can be useful, but care must be taken to avoid running afoul of their requirements, as a recent Tax Court case illustrates.
The close of deferral: Planning for the QOZ end game
Many investors in qualified opportunity zones face a large upcoming tax hit when their QOZ deferral ends. They should consider harvesting stock market losses in advance of it.
Stock-based compensation: Tax forms and implications
While the benefit of equity compensation packages is easy to understand, the same cannot be said of the tax implications, and this article provides a broad overview of them.
How compensatory intent affects compensation deductions
For a corporation to deduct a payment made to a shareholder/employee as compensation, compensatory intent must exist.
Pillar 2: Time for US multinational enterprises to act
Large U.S. multinationals can take steps now to assess the potential impact of the global top-up corporate tax system that appears on the verge of being implemented.
Is it a trade or business? Or a hobby or investment?
Many Code provisions apply only to a โtrade or business.โ This article discusses the various tax consequences when an activity fails the relevant test and is instead deemed a hobby or investment.
Taxpayersโ rights in the Internal Revenue Manual
Being familiar with the taxpayer rights provisions can be helpful because the manual is essentially an employee handbook that IRS employees must follow.
Advance pricing agreements: A realistic option for transfer pricing
In the long run, an agreement with a taxing authority is often a wiser choice than traditional compliance and dispute resolution methods.
Smart tax strategies for lottery winners
Did a client finally hit their lucky number? Hereโs why you should convince them to elect installment payments over the lump-sum option if they win millions in the lottery.
Practical ways to enhance operational transfer-pricing processes
For companies that engage in intercompany transactions, being proactive in preparing for disruptions and regulatory changes is essential.
ESG and taxation: A necessary part of a companyโs strategic objectives
Businesses are likely to find themselves at a competitive disadvantage if they donโt keep abreast of tax aspects of ESG.
R&D creditโs interplay with the employee retention credit
Much confusion surrounds the rules governing which wages can be used to claim the ERC and R&D tax credits.